AML policy

Between the Bollet N.V. and a Client

General Provisions:

This document describes the anti-money laundering policy of the Bollet N.V. (hereinafter - Company) and its
involvement in detecting and preventing any activity connected with money-laundering, financing terrorism and
potential use of the Company’s products and services with a purpose of money-laundering (hereinafter- AML policy).

Laundering proceeds of crime – is the action of conversion money or other money-and-credit instruments,
derived from criminal activity, into the money or investments that seem lawful so that its illegal source
cannot be tracked. Domestic and international legislations, applied to the companies whose clients can deposit
on and withdraw monetary funds from their accounts, make it illegal for the Company’s partners to deliberately
effect or participate in financial transactions with the criminalized monetary funds.

The aim of the anti-money laundering procedures is to guarantee that the clients, participating in financial transactions
with the involvement of the Company site, are identified under reasonable standards with the minimum identity data set
for the law-abiding clients. The company has developed the internal anti-money laundering and combating the financing
of terrorism policy in accordance with the international legislation requirements. The company carefully monitors any
suspicious actions and transactions and reports such actions to the appropriate authorities in due time.

In order to minimize the risks of money laundering and terrorism financing the Company does not receive cash on a deposit
and does not make any payments in cash under any circumstances. The Company reserves the right to abandon the transaction
processing at any stage in case if the transaction deems to be in any way connected with the money laundering or criminal
activity. In accordance with the international legislation, the Company is not entitled to inform a Client that his
criminal activity has been reported to the appropriate authorities.

Identification:

The minimum required identity data set necessary for opening an account includes:

Full name (surname, name and patronymic name);

Registration and financial e-mail;

A Client’s residential or business address;

In order to execute the anti-money laundering laws the Company can demand from its Client to present two documents verifying his
identity. The first document that can be demanded by the Company is an unexpired identification document that bears a Client’s photograph
issued by the jurisdictional government. It can be a passport, a driving license (for the countries where a driving license is a primary
identification document) or a local identity card (except an in-company access card). The other document that can be demanded by the
Company – is a bill, aged less than three months, containing the full Client’s name and actual address. It can be a bill for housing
services, a bank statement or any other document that confirms a Client’s address. In some cases the Company can also request a Client
to present notarized copies of the documents.

The documents written on the languages other than English should be translated into English by a sworn translator; the translation should
be typed and signed by a translator and sent enclosed with a copy of an original document that bears a clear Client’s photo.

Replenishment of the account, funds withdrawal:

The Company demands that during the operation of a replenishment the funds sender’s name fully corresponds the name, specified during the
account registration (in case when a payment system provides a funds sender’s name). Acceptance of payment from the third person is prohibited.

The company has the right to demand a strict adherence to commonly agreed procedures of funds replenishment and withdrawal. The money can be
withdrawn to the same account and by the same means as the replenishment was performed. During the funds withdrawal the receiver’s name should
strictly correspond to the Client’s name in the Company’s database. In case the replenishment was performed by means of a bank transfer, the
funds can be withdrawn solely by the bank transfer to the same bank and account from which the replenishment was made. In the event that
replenishment was performed via electronic payment system, the funds can be withdrawn by means of an electronic payment to the same system
and the account from which the replenishment was performed. The Company is entitled, upon own discretion, to perform a transfer on the requisites
on which the replenishment of the account was performed.

The Company declares that for the purpose of following the anti-money laundering policy, the money transfers made by the Company’s clients are
allowed only in the aim and within the range of the services offered by the Company. Should the Company has sufficient reasons to believe that
funds transfers are used by an account owner with violation of legislation and/or Company’s anti-money laundering policy for the purpose different
from the services offered by the Company, the Company reserves the right to block a Client’s personal account for conducting any transactions from
this personal account.
If you have any additional questions, please, contact us via e-mail: support@inbet.zendesk.com